Corporate Tax
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Featured Articles
Featured Articles: Corporate Tax
US Tax Trends and Developments
Jim Fuller
FIN 48, so well known that nobody would cite it as Financial Accounting Standards Board Interpretation 48, and FAS 109, FASB Statement 109: Accounting For Income Taxes, have resulted in a substantial change in the amount of publicly available information with respect to a publicly held corporation’s taxes and tax reserves.
Development in International Taxation
Friedrich Hey
Last year this author looked at trends and identified developments in the EU as a key area of focus, notably the jurisprudence of the European Court of Justice and the impact it has on tax legislation in the 25 member states. In that respect some of the predictions proved right, while others fell short of expectations.
The Changing Face of UK Taxation
Steve Edge
A Labour government has now been in power in the UK for 10 years. How have things changed in a fast moving international environment and against the background that a previous Labour chancellor pursuing socialist policies in the 1960s had promised “to squeeze the rich until the pips squeak”? What has New Labour delivered on the tax front?
Corporate Governance: A New Life or the Kiss of Death for International Tax Lawyers?
Philip van Hilten
In recent years financial scandals caused many to rethink ways in which management of responsible companies should behave. Corporate governance is today’s motto. Companies should be totally transparent and management should certify that nothing remotely debatable is hidden. None could speak out against this almost religious approach demanding accounts to reflect the truth and nothing but the truth.
A Forecast of Taxation Developments
Michael O'Connor
Chief tax officer Alcan Inc, Montreal
Welcome to the tax introduction of the 2007 International Who’s Who of Business Lawyers, a thought-provoking stretch of taxation filler and a must-read for all lawyers, legal wannabes (ie, tax accountants and auditors), and those who need their services. I have been given free reign; and sitting here on New Year’s day ploughing through this task, I have designed this introduction as a forecast of taxation developments that will shape the year to come.
Canadian Tax Aspects of Creating Leverage in Subsidiary Operations
Richard Tremblay
Gregory Wylie
Multinational groups with Canadian subsidiaries are typically keen to adopt strategies to introduce leverage into their Canadian operations. The goal is to use deductible interest to reduce the Canadian subsidiary’s (‘Canco’) tax rate. Other considerations can also come into play. Foreign tax credit planning, for example, can mandate that funds be repatriated from Canada. This introduction is an overview of select Canadian tax considerations, relevant to a multinational group undertaking a financing transaction to introduce leverage into Canco.
Current Trends In the European M&A Market and Their Tax Effects
Philip van Hilten
Mark van Casteren
2005 was a record year for the European mergers and acquisitions market. Thomson Financial reported more than 40 US$1 billion-plus deals completed in 2005 and a total of US$151 billion in private equity funds deployed on European buyouts.
Current Tax Issues in the US
Jim Fuller
Transfer pricing is always an important subject in the US, as it is elsewhere. Some years back, the IRS adopted the Advance Pricing Agreement programme, which seemed to provide an outlet, and a means, for eliminating transfer pricing disputes with the Internal Revenue Service. The APA programme, by all accounts, has been quite successful. But three areas of concern remain.
And Now, Only Death is Certain...
Jan Kruger
Director legal services: structured debt finance
Benjamin Franklin (1706-1790) in a letter to Jean Baptiste Leroy said: “In this world nothing is certain but death and taxes.” In the present international corporate tax environment, this statement may no longer remain true… with respect to taxes anyway. This introduction will focus on the issues at play in the international arena of corporate tax, how large companies employ outside counsel and what qualities they look for.
Developments in International Taxation
Friedrich Hey
Let us look at trends. The EU now has 25 member states and is – next to the United States – the biggest market in the world.
Editorial
Editorial: Corporate Tax
Editorial: Corporate Tax in Georgia
Thirteen corporate tax leaders from six firms appear in this chapter. Experts have a wide range of specialisations: international tax specialists are included alongside domestic experts, direct taxation practitioners, indirect tax lawyers and specialists on transfer pricing and tax issues deriving from M&A and dispositions, are all recognised for their outstanding ability in the legal aspects of corporate taxation.
Editorial: Corporate Tax in Illinois
Illinois is a significant area for corporate tax law and is home to some exceptional talent. The research for this chapter has identified 23 leaders in the field from 10 firms.
Lawyers
All Lawyers in Corporate Tax (Listed Alphabetically)
Click on the name of a lawyer below to view their profile. Lawyers shaded in purple have professional biographies in one or more practice areas.